The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued General License 52C, fully replacing the previous version, 52B. The document authorizes certain transactions with the state-owned oil company PDVSA and entities it directly or indirectly owns at least 50% of, but introduces strict conditions: commercial disputes arising from contracts must be heard in courts in the United States, the United Kingdom, France, or Singapore designated in advance. Monetary payments to blocked persons must be directed to special government or Treasury accounts; the only exception applies to local taxes, permits, and fees.
The license also permits dealings with the Venezuelan government when necessary for authorized PDVSA transactions, while maintaining broad restrictions. Transactions involving government bonds and Venezuela’s or PDVSA’s existing debts are prohibited, as are the sale, transfer, or use as collateral of the Venezuelan state’s stakes in oil companies. The document does not authorize the enforcement of judgments, seizures, or arbitration awards that would change ownership of blocked assets, and excludes individuals and entities on the U.S. Specially Designated Nationals (SDN) list. Restrictions remain in place regarding Russia, Iran, North Korea, and Cuba. Exporters of oil and petroleum products to markets outside the United States must report the parties to the transaction, amounts, dates, and delivery destinations within ten days of the first shipment and every 90 days thereafter. At the same time, the ownership structure of Citgo Holding, PDV Holding, and CITGO Petroleum Corporation remains protected from changes.
Full version: U.S. Issues General License 52C to Regulate Operations with PDVSA Under New Conditions